Digital Product Passport 2026: What the ESPR Actually Requires

The Regulatory Framework: What the ESPR Actually Requires

With the ESPR Regulation (EU) 2024/1781, the EU has established a binding legal framework for the Digital Product Passport (DPP). What surprises many companies: the regulation text is remarkably vague on key technical questions. It merely stipulates that the DPP must contain "up-to-date and accurate information" — with no update frequency, no service-level agreements, and no technical specification for data formats or transmission layers.

This is not an oversight — it's by design. The European Commission delegates the detailed specifications to product-group-specific implementing acts, which are being adopted incrementally. For manufacturers, this means the ESPR alone is not sufficient as a planning basis. What matters is which delegated acts have already been published — or are in preparation — for your specific product category.

What the Regulation Text Actually Specifies

The ESPR establishes the following core obligations:

Unique product identifier: Every product must be linked to a digital product passport via a machine-readable data carrier — in practice, typically a QR code.
Data accessibility: The information stored in the DPP must be accessible to authorities, economic operators, and — depending on the product category — consumers as well.
Data currency: The passport must contain "up-to-date and accurate" information — a formulation that leaves considerable room for interpretation.
Interoperability: The Commission is tasked with defining common data schemas and interfaces; until then, existing standards such as GS1 Digital Link serve as the de facto reference.

What the regulation explicitly does not address: whether data is stored centrally or in a distributed manner, which blockchain or cloud infrastructure is permissible, and how frequently dynamic data must be updated.

The Digital Battery Passport: The First Concrete Mandatory Project

The most fully developed DPP to date is the Digital Battery Passport, which becomes mandatory on February 18, 2027 under the Battery Regulation (EU) 2023/1542. It initially applies to industrial batteries, traction batteries (EV), and stationary storage systems of 2 kWh or more.

The Battery Regulation is considerably more precise than the ESPR: it prescribes specific data points — including capacity, service life, carbon footprint, material composition, and supply chain information for critical raw materials. The product-specific carbon footprint (PCF) must be calculated and declared using ISO 14067-compatible methods.

Real-World Challenges According to the 2026 Implementation Report

The Minespider Implementation Report 2026 analyzes the current state of compliance readiness in the battery industry and identifies two central practical challenges:

Data fragmentation: Relevant data — raw material origins, processing steps, recycling rates — is scattered across dozens of suppliers and systems. There is no unified standard for data exchange between Tier 1, Tier 2, and Tier 3 suppliers.
Dynamic data updates: Battery data is not static. Capacity degradation, charge cycles, and maintenance events must be tracked throughout the entire product lifecycle. Many companies still lack the technical infrastructure to do this.

On June 24, 2026, the BatteryPass Ready project launched its public test environment, where companies can validate their DPP solutions against EU requirements — a significant milestone for the industry, even though the mandatory deadline is still eight months away.

Steel Products as a Benchmark

A look at the JRC data draft for steel products illustrates how detailed product-group-specific requirements can become: the JRC draft explicitly requires the PCF at batch level and mandates ISO 14067-compliant calculation methods. This level of precision goes far beyond the general ESPR language and offers useful clues about future sector-specific requirements.

The Greenwashing Ban and EmpCo: The Underestimated Parallel Track

Running in parallel with the ESPR, the EmpCo Directive (EU) 2024/825 entered into force, prohibiting misleading environmental claims in B2C contexts. The connection to the DPP debate is direct: anyone advertising sustainability claims on packaging or in online retail will need to back those claims with verifiable data — and the DPP is the natural instrument for doing so.

For e-commerce companies, Ecommerce Europe published concrete recommendations in a June 2026 position paper: the industry association calls for flexible data granularity and a phased implementation approach to avoid duplicated effort. The paper specifically warns against dismantling existing product data structures entirely before the EU has defined unified schemas.

Infrastructure: From Standard to Data Carrier

GS1 Digital Link as the Technical Bridge

The practical implementation of the DPP depends on the physical link between a product and its data record. GS1 Digital Link has emerged as the de facto standard here: a structured URL that encodes the GTIN, serial number, and additional attributes, pointing to a resolver that delivers different data sets depending on context.

The Driscoll's example illustrates the scalability of this approach: at GS1 Connect 2026, the berry producer demonstrated how more than one billion berry packages were given unique identities and are currently migrating to fully GS1 Digital Link-compliant QR codes. The project connects consumer feedback directly to farm-level traceability — a model that is likely to become relevant for DPP requirements in the food sector.

Printing Infrastructure as a Bottleneck

A practical and often underestimated challenge: not every packaging substrate can be printed with high-precision QR codes using conventional printing methods. The partnership between Polytag and DataLase, announced in June 2026, addresses exactly this bottleneck: using laser-reactive printing technology, GS1-compliant QR codes can be applied permanently and at production speed to difficult substrates — metal, glass, and plastic films.

For manufacturers that need to introduce item-level serialization (i.e., unique codes per individual product rather than per batch), printing infrastructure represents a real capital investment that is frequently underestimated in DPP project plans.

What You Should Do Right Now

The regulatory landscape can be distilled into three areas of action:

1. Clarify your product category and timeline Not all products fall under DPP obligations at the same time. The Battery Regulation applies from February 2027; for textiles, electronics, and other categories, consultation processes are still ongoing. You should check which delegated acts for your product group have already been published or are in draft form.

2. Define your data strategy before selecting a system The choice of technical platform — whether a central repository, a distributed network such as Hedera, or a hybrid approach — is secondary to the question of which data you need, and at what level of granularity. The JRC steel approach (batch level, ISO 14067) shows that product-group-specific requirements can deviate significantly from the ESPR baseline.

3. Build serialization infrastructure early Item-level serialization requires changes to printing infrastructure, ERP systems, and resolver architecture. If you wait until the implementing acts for your product category are finalized, you may not have enough lead time for the technical rollout.

The ESPR is not a paper tiger — but it is also not a finished rulebook. Starting your analysis now buys you the flexibility you'll need for implementation.